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1989 (8) TMI 110 - AT - Income TaxExtract: .......hich favours the assessee must be preferred to the interpretation which favours the department. The result is that the penalty order passed by the Income-tax Officer on7-10-1983having been passed after the period of limitation prescribed under section 275, the penalty cannot be upheld. 11. In the result, the appeal filed by the assessee is allowed.
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